On April 23, 2026, the U.S. Department of the Treasury (Treasury) announced that the Internal Revenue Service (IRS) will revise Form 990 to require non-profit organizations to disclose more detailed information regarding organizational governance and fiscal management. Accordingly, the agency indicated that it expects to issue a proposed notice of rulemaking later this year.  Treasury’s press release is available here: Treasury Announces Form 990 Transparency Initiative to Expose Hidden Funding and Strengthen Oversight | U.S. Department of the Treasury

Current Form 990 Reporting Requirements

Tax-exempt organizations are currently required to file an annual Form 990 to report gross income, receipts, disbursements, and other information pursuant to 26 U.S.C. 6033. Federal regulations also require disclosure of names and addresses of all officers, directors, or trustees. In addition, tax-exempt organizations must report their total number of employees, highly compensated employees, and independent contractors, including names and addresses. See 26 CFR 1.6033-2.

Form 990 filings are publicly available and serve as a key source of information regarding an organization’s operations, including:

• Part I: High-level overview of organizational finances
• Part III: Description of mission and program changes
• Parts VI and VII: Governance structure and reportable compensation of key personnel
• Part VIII: Detailed statement of revenue

Expected Impact on Tax-Exempt Organizations

Although the IRS has not yet released the specific proposed changes to Form 990, tax-exempt organizations should begin evaluating their internal policies and procedures related to financial reporting and governance. Based on currently available information from the Treasury, the anticipated changes are likely to increase scrutiny of an organization’s finances, mission-related activities, and overall fiscal management.

Organizations may wish to proactively assess the consistency, accuracy, and completeness of data collected across operational areas in preparation for expanded disclosure requirements.

Feldesman will continue to monitor developments related to tax-exempt organization regulations, including forthcoming changes to Form 990. For questions or additional guidance, please contact Phillip A. Escoriaza or Kevin R. Lutes.